Submitted via E-mail: NOAA.Aquaculture@noaa.gov

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November 30, 2006
   
Michael Rubino, Ph.D
NOAA Aquaculture Program
1315 East-West Highway
Room 13117
Silver Spring, MD 20910
 
Re: Comments on 10-Year Plan for the National Oceanic Atmospheric Administration (NOAA) Aquaculture Program

Dear Dr. Rubino: 

Food & Water Watch, a nonprofit consumer rights organization that challenges corporate control and abuse of our food supply and ocean resources, is please to provide specific comments on the Interim Final 10-Year Plan for the NOAA Aquaculture Program.  

A major part of our mission is to educate consumers on the costs and benefits of consuming seafood and the crisis confronting wild fish resources. Our previous administrative and legislative advocacy focused on ensuring consumers a supply of healthy sustainable fish, while protecting the marine environment and ensuring the preservation of small-scale fisheries dependent communities. 

The outline of the strategy as expressed in the Interim Final 10-Year Plan for the NOAA Aquaculture Program takes an extremely narrow view of the potential promises associated with new technologies and innovative practices that may play a critical role meeting the food and fiber needs of society. In addition, the plan acts more as a promotional publication for Open Ocean Aquaculture, rather than an actual plan with specific timelines and mechanisms to address challenges associated with the industry.

NOOA should exercise extreme caution when developing any Open Ocean Aquaculture program.  We raise objections to the Agency’s Interim Final 10-Year Plan because the plan (a) promotes an inferior method of Programmatic Environmental Impact Statements which is not sufficient in protecting marine resources, (b) lacks consumer protection initiatives, (c) contains insufficient provisions for protecting the financial interest of traditional fisheries dependent communities, and (d) ignores states rights and jurisdiction over the planning, regulation and monitoring of open ocean fish farms.

Issue Overview
 
In the Interim Final 10-Year Plan for the NOAA Aquaculture Program, the Agency lists seemingly compelling facts to support a case for the expedient development of a domestic marine aquaculture industry in the U.S.  The Agency lists the following as a basis for its Interim Final 10-Year Plan:

• Americans consumed 16.6 pounds of seafood per person in 2005, up from 16.3 pounds per person in 2004.
• Nutritionists are encouraging Americans to double our consumption of seafood, from one seafood meal per week to two.
• Of the 6 million metric tons of seafood consumed in the United States each year, 1.5 million is provided by domestic commercial fisheries and 0.5 million is provided by domestic aquaculture.
• The U.S. aquaculture industry currently produces about 500,000 metric tons of seafood per year, with a farm-gate value of $1 billion.
• To meet current demand, each year the United States imports almost 70 percent of its seafood, or 4 million metric tons—about half of which is from aquaculture.
• The current U.S. seafood trade deficit is almost $8 billion. 

These facts are without doubt persuasive, and on first glance can be deemed important policy drivers when increasing globalization of the seafood industry has significantly changed the domestic market and availability of seafood. Also, the impact of globalization can be recognized by a steadily growing U.S. seafood trade deficit, currently hovering around $8 billion.  

However, we cannot look at these facts in a vacuum. As the Agency undertakes the initial stages of the development of a domestic open ocean aquaculture plan, a more pragmatic approach must be centered on sustainability of ocean resources.  

The current state of our oceans gives credibility to this approach. 

The global demand for seafood has resulted in the overfishing and depletion of critical fish populations.  In an analysis of scientific data going back to the 1960s and historical records over a thousand years, researchers found that marine biodiversity – the variety of ocean fish, shell fish, birds, plants and micro-organisms – has declined dramatically, with 29 percent of species already in collapse. The researchers indicate that by extending this pattern into the future, the scientist calculated that by 2048 all species would be in collapse. Open Ocean Aquaculture will only exacerbate this problem, rather than solve it.

Food & Water Watch is concerned with the development of large-scale commercial fish farms in federal waters. Open Ocean Aquaculture involves raising carnivorous finfish, such as cod, halibut and red snapper crowded cages where fish waste and chemicals flush straight into the open ocean. These large farms can introduce escaped non-native fish species that compete with and spread disease to wild-fish populations. Damage to the farms from storms is one of the primary ways that farm-raised fish can escape. For example, in the late nineties, storms destroyed an offshore aquaculture test-cage placed adjacent to an energy platform in the Gulf of Mexico. In addition, these species are dependent on wild fish for feed, thus increasing the pressure on wild fish populations.

We are also concerned about the impact of open ocean aquaculture on rural fishing communities. 

The Interim Final 10 Year plan does not provide enough details to give the public and stakeholders notice of the intricacies of a domestic Open Ocean Aquaculture Program. In fact, some portions of the Interim Final plan has not receive the approval of the relevant committees of jurisdiction within the 109th Congress. 

For example, the U.S. Senate made successful attempts to reject Section 19 of H.R. 4761, as approved by the House of Representatives. As you are aware, Section 19 of H.R. 4719 would allow the Minerals Management Service (MMS) to authorize use of decommissioned offshore oil and gas platforms for “an artificial reef, scientific research, or any other use authorized under section 8(p) [of the Outer Continental Shelf Lands Act] or any other applicable Federal law.” This provision – particularly the “other use” clause – could allow MMS to authorize fish farms in federal waters and could allow oil companies to evade liability and platform removal responsibilities.

Another relevant example is found in the U.S. Senate’s rejection of the U.S. House version of the Magnuson Stevens Reauthorization of 2006. While there were many problems with the House version of the bill, the Senate especially expelled the House provisions that would truncate the necessity to undertake complete and thorough environmental impact statements. The Interim Final Plan mirrors the House approach by advocating Programmatic Environmental Impact Statements rather than an EIS that requires accumulative impact analysis. 

In addition, NOAA must acknowledge that the increase of seafood production in U.S. waters will require an increase in inspections of domestic seafood.

Food & Water Watch believes that the Agency should revise the Interim Final Plan 10 Year Plan to respond to our specific concerns below.

A.    A Programmatic Environmental Impact Statement is an inferior approach to protecting critical ocean resources and habitats. 

In its efforts to promote Open Ocean Aquaculture, the Agency should utilize environmental approaches that will contribute to reducing the adverse environmental impacts of documented problems associated with Open Ocean Aquaculture. The Interim Final 10 Year Plan indicates the use of Programmatic Environmental Impact Statements rather than an approach that espouses accumulative impacts. Programmatic Environmental Impact Statements by nature are generalized environmental protection methods that place little attention on the accumulative impacts on an ecosystem. While this approach may be suitable for Mountain Top Mining, it would result in the total destruction of fragile multispecies ocean ecosystems.

Our reason is based on the following facts:

Depletion of Wild Fish to Feed Farmed Fish: Several pounds of wild fish in the form of fish feed can be required to produce one pound of farmed marine finfish. This represents a net loss in fishery resources.

Escaped Farmed Fish Jeopardize Wild Fish Populations: Large numbers of fish can escape from ocean fish farms. Escaped fish – particularly if they are non-native or genetically distinct from wild populations – could threaten wild fish populations by competing with them for food and habitat and interbreeding with them. In fact, the risk of escapes could be significant because fish farms could be placed farther from shore where weather conditions are more severe.

Pollution of Water and Local Ecosystem: The concentration of fish waste, uneaten fish feed, pesticides and antibiotics can overload local ecosystems with chemicals and nutrients.

Parasites & Disease: Pathogens and parasites that occur at low levels in the wild, can multiply rapidly in the crowed conditions of fish farming facilities and can transfer to wild fish populations.

B.     It lacks consumer protection initiatives.

To increase growth rates of farmed fish and prevent deaths, many fish farms use hormones, algaecides, pesticides and other chemicals that can pose serious health risks to consumers. Moreover, PCBs and other contaminates found in wild fish can concentrate in farmed carnivorous fish. High levels of mercury are also known to exist in both the soils and fish caught near oil rigs due in part to the use of mercury-laden drilling solutions. The health impacts associated with these various contaminants range from cancer to neurological disorders and learning disabilities.  

In addition, recent reports have highlighted a connection between oil and gas rigs and elevated mercury levels in surrounding sediments and wild-caught fish. Data from a U.S. MMS study in 1996 of three rigs in the Gulf of Mexico revealed that sediments within a few hundred feet of two rigs had mercury levels many times higher than base levels in Gulf of Mexico sediments. Data also indicated that shrimp and fish caught beneath the rig with the most contaminated sediments had average mercury levels that were two to five times higher than those caught around the least contaminated rigs. Scientists attribute the mercury contamination in and around the rigs to drilling “muds,” which are a mercury-rich mixture of the sediments and materials that cool and lubricate drill bits that bore into the ocean and are ultimately discharged into the ocean. Raising fish in this environment will only increase the negative impacts to consumers.

Increased seafood inspection is necessary if there is increased seafood production in U.S. waters. Without a specific plan from the Agency, the public can only believe that the Interim Final 10 Year plan will not ensure that consumers receive safe and healthy seafood. In its current form, the plan’s implementation of a domestic Open Ocean Aquaculture program will not be accompanied by a safe seafood inspection program.

C.    The Agency Plan has not laid out a plan of economic assistance for Traditional Fisheries Dependent Communities. 

Open Ocean Aquaculture would have a significant impact on the viability of traditional fisheries dependent communities. The wide spread use of commercial fish farms may create new jobs, but the practice would place at risk various fishing communities. The Interim Final 10 Year plan does not address the financial burden placed on these communities when the statutory authority currently exists. 

When a major policy change is enacted, relevant economic programs need to be developed. The Agency’s plan provides no direction on how it would use the Magnuson-Stevens authority to protect the financial interests of dependent communities.

Aquaculture off the U.S. coast may harm the existing U.S. fishing industry by lowering prices for wild fish caught by U.S. fishermen. In the 1990s, increased imports of low-cost farmed salmon contributed to financial instability of fishing communities.

Furthermore, U.S. Open Ocean Aquaculture may only benefit a few foreign companies, especially if the industry follows the same trend as the salmon farming industry. In 2001, thirty companies produced two-thirds of the world’s salmon and trout.  The biggest companies are multinational corporations from Northern Europe. Pan Fish and Cermaq are both based in Norway. In June 2006, Pan Fish became the largest fish farming corporation in the world, after taking over its two competitors: Marine Harvest and Fjord Seafood. Pan Fish is now worth about $2.5 billion.   Nutreco is based in the Netherlands and leads the fish feed industry. Stolt-Nielsen is based in Luxembourg.  These corporations are vertically integrated, controlling every step of the process, from feed production to fish farming to processing and distribution.  By 2003 in British Columbia five companies, George Weston, Pan Fish, Nutreco, Stolt-Nielsen, and Cermaq own 83% of the aquaculture leases, down from 50 companies in 1987. 

D.    It ignores states rights and jurisdiction over the planning, regulation and monitoring of open ocean fish farms.

Some states have already indicated that they do not want marine fish farms in their waters. In Spring 2006, California passed a bill – the Sustainable Oceans Act – that set standards for any marine fish farm operations in state waters. Those standards are much more stringent than any proposed by NOAA. The State of Alaska’s position is that there should be a 5-year moratorium on any finfish aquaculture in federal waters until certain social and environmental studies are conducted. In addition, for many years, Alaska has a complete ban on finfish aquaculture in state waters.

Conclusion

Stakeholders and the U.S. Congress look to NOAA to provide guidance on the management of ocean resources. The U.S. Congress will most likely give a fresh look at these issues during the 110th Congress.  In its present form, the Agency’s Interim Final 10 Year plan does not give the appropriate guidance on an issue as critical as Open Ocean Aquaculture. 

Respectfully Submitted,



Quinton Robinson
Legislative Representative
Food & Water Watch